Transportation to Slaughter: Proposed Regulations

 

United States Department of Agriculture (USDA) regulations governing the transportation of horses to slaughter facilities are, relatively speaking, nearing the implementation stage. The transportation of horses to slaughter issue long has been a focus of animal welfare groups, but it wasn't until 1996 that the U.S. government took official action. As part of the Farm Bill that year, Congress directed the Secretary of Agriculture to establish and implement regulations that would insure the humane transportation of horses to slaughter facilities.

Ultimately, the job of creating the regulations was passed to Veterinary Services of APHIS (Animal and Plant Health Inspection Services). Heading up the effort for the Veterinary Services has been Tim Cordes, DVM, Senior Staff Veterinarian, Equine Programs.

It is not the role of the Department of Agriculture either to condone or condemn the human consumption of horse meat, Cordes said, but the department does involve itself with all phases of agriculture. For Cordes, who was in private veterinary practice for many years before joining the USDA, involvement as the Veterinary Services representative responsible for spearheading the effort to fulfill the requirements was a challenging learning experience.

�I knew nothing about the slaughter horse industry,� he said, �and I�m sure the same can be said of a great many veterinarians in the field today. I had to educate myself.�

Before he finished his �education,� Cordes visited the horse slaughter facilities in the United States and also took an active part in research efforts aimed at learning more about the stresses horses undergo when being transported.

One of the key components of the proposed regulations, something that came out of the research, is the elimination of double-deck trailers for the transportation of horses to slaughter facilities. However, there is a grandfather clause. This part of the regulations will not be implemented for five years in order to give truckers time to replace their double-deck trailers. Under the proposed regulations, only single-deck trailers that are of a size to allow the tallest horse being hauled to have sufficient head room will be permitted. However, double-deck trailers with �floating decks� that can be raised or lowered will meet the standards proposed, providing that the �floating deck� is lowered so that the trailer is a single-decker.

The trailer requirement is only one of many rules included in the proposed regulations. There are a number of other requirements that came after a good deal of expert study and discussion, said Cordes. Providing input on establishment of the regulations was a select panel of one representative each from the USDA, American Horse Council, Animal Welfare Council, New Holland Sales, Inc., American Horse Protection Association, American Humane Association, The Humane Society of the United States, American Association of Equine Practitioners, American Veterinary Medical Association, managers of each of the three largest equine slaughter plants, and researchers.

The panel, armed with information from a number of research projects, worked to determine what should be covered in the regulations. The group was able to reach consensus on nearly all key points, said Cordes.

As part of the effort to obtain data concerning the transportation of horses by commercial conveyances, the USDA funded studies at three universities. Research was carried out at the University of California, Davis, Texas A&M University, and Colorado State University. Cordes was personally involved in the Texas A&M research work.

USDA Proposed Regulations: Space

The animal cargo space of conveyances used for the commercial transportation of horses to slaughter facilities must do the following:

1. The conveyance must be designed, constructed, and maintained in a manner that at all times protects the health and well-being of the horses being transported. This means the conveyance must provide adequate ventilation and contain no sharp protrusions, etc.

2. The conveyance must include a means of completely segregating each stallion and each aggressive horse on the conveyance.

3. The conveyance must have sufficient interior height to allow each horse loaded thereon to stand with its head extended to the fullest normal postural height.

4. The conveyance must be equipped with doors and ramps of sufficient size and location to provide for safe loading and unloading.

5. Horses being commercially transported to slaughter facilities must not be transported in any conveyance that has the animal cargo space divided into two or more stacked levels. However, trailers lacking the capability to convert from two or more stacked levels to one level may be used for five years from the date of publication of the final rule. Conveyances with collapsible floors (also known as �floating decks�) must be configured to transport equines on one level only.

There also is a list of requirements for the shipper prior to loading the horses for transport.

1. For a period of not less than six consecutive hours prior to the horses� being loaded on the conveyance, the animals must be provided with appropriate food and water and an opportunity to rest.

2. A USDA backtag must be applied to each horse in the shipment.

3. An owner-shipper certificate for each horse being transported must be completed and signed. This must accompany the horse throughout the shipment and must contain the following information: The shipper�s name and address; a description of the conveyance, including license number; a description of the horse�s physical characteristics, including such information as sex, coloring, distinguishing markings, permanent brands, and any electronic means of identification; a statement of fitness to travel, which will indicate that the horse is able to bear weight on all four limbs, is able to walk unassisted, is not blind in both eyes, is older than six months, and is not a pregnant mare that would be likely to give birth during the trip; a description of anything unusual concerning the horse�s physical condition, such as a wound, etc.; the date, time, and place the horse was loaded; and a statement that the horses were provided access to food, water, and rest prior to transport. Each horse�s backtag number also must be recorded.

The stipulation that horses must be fed, watered, and rested during the six hours prior to being transported is that research showed if horses are fed and watered during that time, they are better able to handle the stresses of a trip that might last as long as 30 hours before suffering from serious dehydration and other travel related problems, said Cordes. The maximum amount of time a horse going to slaughter will be permitted to remain aboard a conveyance is 28 hours. �That is sufficient time for a shipper from about anywhere in the United States to make it to one of the slaughter houses,� Cordes said.

Travel Responsibilities

The regulations also address the type of load to be transported.

1. Each horse must have enough floor space to ensure that there is no crowding to the point that discomfort and injury could result.

2. Each stallion and any aggressive horse must be completely segregated.

The regulations also deal with proper driving of the conveyance.

1. The driver must drive in a manner to avoid causing injuries to the horses.

2. The driver must observe the horses as frequently as circumstances allow, but not less than once every six hours, to check on the physical condition of the horses. Veterinary assistance must be provided as soon as possible for any horses in obvious distress.

3. The driver of the conveyance must offload any horse which has been on board for 28 consecutive hours. Once the horses have been offloaded, the shipper must provide them with appropriate food and water, plus an opportunity to rest for at least six consecutive hours. If offloading is required, the shipper must prepare another owner-shipper certificate and record the date, time, and location where the offloading occurred. Under this scenario, both owner-shipper certificates must accompany the horses to the slaughter facility.

4. Electric prods may not be used on horses in commercial transportation to a slaughter facility for any purpose, including loading or offloading on the conveyance, except when human safety is threatened.

5. At any point during the trip, the conveyance may be stopped and inspected by a USDA representative. That representative will be empowered, if he or she deems it necessary, to secure the services of a veterinary professional to treat any horse, including euthanasia if necessary.

At The Slaughter House

The shipper�s responsibilities do not end with arrival at the slaughter facility. Once there, the shipper must do the following:

1. Ensure that each horse has access to appropriate food and water after being offloaded.

2. Present the owner-shipper certificates to a USDA representative.

3. Allow a USDA representative access to the horses for the purpose of examination.

4. Allow a USDA representative access to the animal cargo area for the purpose of inspection.

The shipper is required to remain at the premises of the slaughter facility until all of the horses have been examined by a USDA representative.

The proposed regulations also take note of the fact that many horses for slaughter are being shipped to Canada, and some to Mexico. The rules state that any shipper transporting horses to slaughter facilities outside the United States must present the owner-shipper certificates to USDA representatives at the border.

Penalties And Fine Points

There is a serious penalty for not adhering to the regulations. A fine of up to $5,000 per violation can be imposed by the USDA. Each horse transported in violation of the regulations will be considered a separate violation.

The proposed regulations will be in effect for �commercial� shippers. Commercial is defined as anyone who transports a horse to slaughter more often than once per year. In other words, a horse owner who hauls a horse to a slaughter facility once would not be considered in the commercial category. However, if that same owner should transport a second horse to a slaughter facility a few months later, the commercial classification would apply and all of the USDA rules and regulations would be in effect for that owner-hauler.

Research Findings: UC Davis

The part of the proposed regulations that do away with double-deck trailers after five years, said Cordes, is based in part on findings from the study conducted by the UC Davis research team headed by Carolyn Stull, PhD, as well as research conducted at Texas A&M. The UC Davis study found that more injuries resulted to horses on double-deck trailers than to those on single-deck trailers or to horses being hauled in gooseneck trailers.

Stull reported that horses hauled in double-deck trailers had an injury rate of 29.2% compared to an injury rate of 8% in single-deck trailers.

She reported that the width of doors and loading ramps likely had something to do with the higher injury rate. The door widths of the straight-deck trailers, she said, were the entire width of the trailers, while that of the double-decker is only about one-third of the width.

�Horses loading into (double-deck) trailers utilized ramps from the door located at the back of the trailer to enter the appropriate compartment,� she wrote in her report, �and this may have contributed to the increase in injury rate of horses in the front (28.6%) and middle (31%) as compared to the rear compartment (16.7%.)�

The study conducted by Stull and her associates included nine trailer loads of horses�a total of 306 animals�transported to slaughter facilities with distances ranging from under 500 miles to nearly 2,000 miles. The trailer loads were assembled in the states of Pennsylvania, Kentucky, California, and Texas. The trips varied in length of time from five hours 45 minutes to 30 hours.

In addition to obtaining information on injury rates, the researchers also collected data that produced helpful information concerning dehydration and other stress factors (such as heat and humidity) associated with long distance hauling.

The researchers found that horses hauled for 16 to 27 hours showed greater evidence of fatigue and dehydration than did horses hauled for shorter times.

In addition, Stull reported, horses hauled for longer periods had a higher injury rate. �Fatigue, dehydration, and stress may be contributing factors to threefold increase in injuries in horses traveling 27 to 30 hours as compared to durations less than 23 hours,� she wrote in her report. �Additionally, the horses in the long duration group have an extended period of time to interact with other horses in the confined area, thus sustaining additional injuries.�

Stull reported on one somewhat conflicting finding. Some of the loads were tightly packed, while others had lighter loads with each horse having more space. She found that the more densely packed loads sustained fewer injuries than those where the horses had more space, but that the densely loaded horses suffered more from transport stress.

She also found that while horses on double-deck trailers suffered a higher injury rate, the horses being hauled in the single-deck trailers seemed to suffer more from heat stress. The single-deck trailer involved in the study was equipped with a lining of rubber padding on the interior walls, and Stull surmised that this might have compromised ventilation.

However, there were no significant differences between the two trailer types in regard to weight loss or dehydration. The mean weight loss of all horses studied was 4%.

The double-deck trailers involved in the study carried up to 44 horses each, while the single-deckers hauled up to 38 horses. All of the trips were made during the hot summer months.

Stull had this to say concerning the type of horses she observed being sent to slaughter and what the data collected seem to imply about transporting them:

�Slaughter horse candidates are middle-aged, mature horses possessing moderately fleshy body condition and usually are Quarter Horse or Thoroughbred breeding. This descriptive data should assist in drafting regulations appropriate to the equine subjects in the U.S. commercial market. Neither trailer design (double-deck nor single-deck) was unequivocally beneficial in minimizing both injuries and physiologic responses to transport in slaughter horses.

�Improvements in trailer design, such as ventilation and door and ramp design, should be addressed. As the duration increases, muscular fatigue and dehydration are the major physiological problems, especially in trips over 27 hours. The optimal floor area per horse in a trailer was not identified based on the selected physiological parameters and injury data. The physiological responses support high floor area, while the number of horses injured was considerably less in trailers with low floor area. These physiological responses may be due to the hot and humid summer conditions, and similar stocking density studies should be performed under other seasonal conditions.�

Research Findings: Colorado State

Another USDA-sponsored study that had an impact on the regulations was conducted by researchers at Colorado State University. One of the researchers, and the author of that report, was Temple Grandin, PhD, an assistant professor at Colorado State. She was assisted by Kasie McGee and Jennifer Lanier of the Department of Animal Sciences. While Stull�s research involved a good deal of scientific data, the Colorado State study relied on firsthand observation. During July and August of 1998, researchers surveyed horses arriving at the Dallas Crown and Beltex slaughter plants in Texas. A total of 1,008 horses were surveyed. Of that total, 42% arrived at the plants in double-deck semitrailers, 9% arrived on straight single-deck semitrailers, and 49% arrived in gooseneck trailers.

(Thirty-six additional loads were observed as part of the study. These loads were either arriving or loading out from the New Holland Sale in New Holland, Penn.)

The average number of horses on each load arriving at the slaughter facilities was 28 for the double-deck trailers, 22 on the single-decks, and 11 in the goosenecks. The maximum number transported on each type of trailer was 45 on the double-deck, 25 on the single-deck, and 22 in a gooseneck.

Ninety-two percent of the 1,008 horses arrived at the slaughter facility in good condition and 1.5% (15 horses) were listed as being not fit for travel.

A total of 78 horses (7.7%) had severe welfare problems. A somewhat grim finding was that 60 of the horses with severe welfare problems were suffering from conditions caused by owner neglect and abuse, not transportation stress or injury. By contrast, only 18 of the 78 had transport and marketing injuries bad enough to be rated as a severe welfare problem.

Three percent (30 head) of the arriving horses were skinny and emaciated and 1% (12 head) were foundered or had obvious leg injuries. The body condition score of these animals, Grandin noted, was 1 or 2. (The lower the body condition score, the more emaciated the animal. A score of 1 indicates an animal whose rib and hip bones are protruding and clearly visible.)

�Owner problems were significantly greater than transport problems,� Grandin reported. �Examples of origin welfare problems were (animals that were) loaded with a broken leg; emaciated; foundered; racehorses with bowed tendons; and horses that were too weak to be transported.�

Grandin and her team examined the horses visually as the animals were offloaded, then examined the carcasses after the horses were slaughtered. This examination proved to be revealing as bruise injuries from fighting frequently showed up on the carcasses, but were not observable prior to slaughter.

Grandin came to this conclusion:

�Fighting was a major cause of injuries during transport and marketing. Thirteen percent of the carcasses had bruises caused by bites or kicks. Fifty-one percent of all carcass bruises were caused by bites or kicks. To reduce injuries, aggressive mares and geldings must be removed and held in separate pens in the same manner as stallions. Loads from dealers who picked up horses from more than one auction had more external injuries and carcass bruises than direct loads (those that were sent from a central holding facility or feed lot directly to the slaughter plant).

�Horses which travel direct to slaughter had fewer external injuries and fewer carcass bruises than horses transported to several auctions. Interviews with dealers indicated that some dealers will go to several auctions to fill up their trailers. Horses bought at the first auction have to be loaded and unloaded several times for feed and water.

�Two double-decks used by known dealers who buy horses at more than one auction were compared to six direct double-deck loads. External injuries were visible on 7.5% of the horses on the multiple stop load and 1.6% on the direct loads. Direct loads had significantly fewer bruises. Bruises were also higher on a trailer load which made multiple stops at several auctions. Bruises on this load were compared to all the other horses that were slaughtered that day.�

While Grandin takes the position that double-deck trailers should not be used for transporting tall horses, she is also of the opinion that prevention of fighting both on board the conveyances and in holding pens at auction yards is a more serious issue. She had these additional comments on fighting:

�The most serious injuries and welfare problems are not caused by the type of trailer the horses are transported in. The number one problem that needs to be corrected in transport and marketing is injuries caused by horse fights. At the New Holland sale, three horses were injured in a fight that occurred in a dealer �drop-off pen.� One horse received a serious eye injury. That horse and several others had been purchased at another sale and they were unloaded at New Holland for feed and water while the dealer purchased more horses. Injuries due to fighting and injuries in general appeared to be worse in loads where strange horses were constantly mixed as new horses were purchased to fill up the load.�

The temperament of some of the horses being sent to slaughter also contributed to fighting, she said. �Behavior problems are a likely explanation for many horses being sold for slaughter,� she noted in her report. �At the New Holland sale, 7% of the horses exhibited misbehavior in the sale ring, such as bucking and rearing. The misbehavior is a likely reason why the horse was being sold.�

Grandin then turned to the team�s observations concerning double-deck trailers:

�Head injuries and back abrasions were elevated in double-decks, but very severe injuries, such as shoulder cuts, are probably not caused by trailer design. Double-deck trailers should never be used for very tall horses. (She categorized �very tall� as being draft breeds and equines taller than 16 hands.) A load containing Belgian draft horses had many animals with abrasions on the back.

One of the reasons why data show a trend for elevated double-deck injuries is that double-deck vehicles appear to be more likely used by traders and dealers who take horses from one sale to the next. Loads that came from known traders or �junk dealers� had a higher percentage of injuries and serious welfare problems.

�Our observations indicate that the particular owner of a trailer may have a greater effect on injuries than trailer design. The responsible dealers and transporters who closely supervise loading, supervise driver behavior, and separate aggressive horses will have a lower incidence of injuries. Double-decks also transported horses for much longer distances than goosenecks. The biggest problem with double-deck trailers is loading and unloading. Horses are sometimes reluctant to walk down the internal ramps in the trailer. On one load, the driver had to poke the horses on the top deck with a stick to induce them to go down the internal ramp in the trailer. Sometimes a horse jumped and fell on the ramp.�

The Grandin team also concluded that load density can have a direct bearing on injuries. One double-deck trailer arrived with 45 horses aboard. Three of them had facial and croup damage that put them in the team�s category as being a �serious� welfare problem.

�The high amount of injuries on this trailer,� Grandin stated, �are likely due to the high load density and continual mixing of strange horses.�

However, she added, loading with too little density also can result in injuries. Horses with too much space, she concluded, might lie down and be stepped on by other horses.

The size of the horse is a key factor when transport by double-deck trailers is involved, Grandin said. She noted that a double-deck trailer load of 44 feed lot colts arrived at the slaughter facility and that not one of them had been injured during transport.

�The animals were small enough not to contact the ceiling,� she noted. �These colts had no marks on them from fighting because they had been raised together.� However, she added, some of them had foundered while at the feed lot.

Grandin concluded her report by stating that she is highly in favor of keeping the remaining horse slaughter facilities in the United States open and functioning. �If the U.S. horse slaughter plants are closed,� she wrote in her report, �it will become impossible to regulate horse slaughter. Horses will cross over into Mexico and disappear. It is important for horse welfare that the remaining four slaughter plants remain open, but the condition of horses arriving at the plants must be improved.�

She also stated that the responsibility for a horse�s welfare rests with its owner. Owners who abrogate that responsibility are the ones who sell horses through �underground� channels.

�A load was observed arriving at a slaughter plant which contained many Standardbred carriage horses and Belgian draft horses that were not fit enough to be sold at New Holland,� she reported. �The New Holland sale will not accept horses that are severely lame or in very poor condition. Twenty-six of the horses were in very poor body condition. This was one of the �underground� loads which bypassed the New Holland sale. Most of the carriage horses and Belgians on this load originated from Pennsylvania.

�The authors are very concerned about the fate of many severely lame or emaciated horses which go into market channels outside of the auctions. The New Holland sale has banned horses with severe welfare problems from their sale. However, horses from the area near the New Holland sale which were severely lame or emaciated arrived at the slaughter plant. They were brought in by a dealer who buys horses that are not sold at an auction.

�It is the horse owner�s responsibility to euthanize a horse which is severely debilitated and not fit to travel. The �junk� horse dealers would not exist if an old or ailing horse was either euthanized or sold for slaughter before its condition deteriorated.�

Research Findings: Texas A&M

The third USDA-sponsored research was conducted at Texas A&M University under the direction of Ted Friend, DVM, of the Department of Animal Science. Four major projects were funded in 1996 and have been completed. A fifth project concerned on-board watering of horses being transported to slaughter. Following is a summary of the first four projects, as reported by Friend.

Project 1�Dehydration and Stress Responses of Horses During Long-Term Commercial Transportation. In this study, non-watered horses were transported 30 hours while horses which received water periodically in transit were transported for 32 hours. More than 30 measurements were obtained from each horse at frequent intervals during transport as well as recovery. �Severe dehydration and fatigue can become a problem in healthy horses when they are transported beyond 24 hours. Horses in excellent condition should not be transported more than 29 hours unless they are unloaded every 24 hours for water, feed, and rest,� Friend wrote in his report.

Project 2�Effect of High Density on the Ability of Horses to Maintain Balance and Dissipate Heat, and on Cortisol Concentrations. High density has an adverse effect on the ability of horses to maintain balance and increases injury rates. �The results of this project,� Friend said, �did not support the old myth that when animals are loaded at very high density, they hold each other up. Density did not influence the ability of horses to regulate thermally as measured in this project (body temperature) due to their great ability to dissipate heat by sweating. Increased sweating, however, will greatly increase dehydration.�

Project 3�Relative Stressfulness and Heat Load During Transport in Multi-Deck Trailers in Hot Weather. Friend left no doubt where he stood concerning the use of double-deck trailers as horse conveyances. �After the initial trial, it was obvious that the transport of horses in typical multi-deck trailers for long distances is not an acceptable practice and should be phased out in the U.S.� However, he reported, �We could not detect an effect of density on heat load as measured in this study.�

Project 4�Strategies Used by Horses to Maintain Balance During Acceleration, Deceleration, and Effect of Orientation. Friend reported that individual horses show a strong preference to orient approximately 45 degrees from the direction of travel, but they do not show a preference to orient either toward or away from the direction of travel. �Lowering their hindquarters appears to be more important than raising or lowering their heads in coping with changes in speed,� he reported.

To obtain data during the above projects, trained observers (Cordes among them) perched atop trailers to observe the reactions of horses as, among other things, the trailer was pulled through an obstacle course at varying speeds. The horses� actions were recorded via cameras mounted on the trailers.

They learned, Cordes said, that when horses were packed to the maximum density point, or near maximum, and aggressive driving was involved, there was serious danger that a horse might lose its balance, fall, and not be able to get back up because other horses on the tightly packed load would instantly fill the standing space vacated by the down horse.

All of the horses used in the above four projects were tame Texas A&M University horses. This was necessary, Friend stated, because the horses had blood samples taken frequently, were weighed with frequency, and underwent veterinary examinations, something that would have been difficult with a group of strange, perhaps unruly, horses.

�Frequent sampling was necessary,� Friend wrote in his report, �so that changes in dehydration, heat stress, and other variables could be accurately documented over time. Although those studies established an important knowledge base, they did not answer several important questions specific to relieving stress in transported slaughter horses.�

The final project conducted at Texas A&M involved watering the horses in transit without offloading them. The researchers found that horses which had been deprived of water for four hours, then transported in hot weather for eight hours, will drink aboard trucks and trailers if water is offered.

However, two prime problems were encountered. In some instances, dominant horses in a load kept others from drinking. The second problem involved developing an efficient water trough.

�Development of a useful on-board watering system for commercial trailers is needed,� Friend concluded in his report. �Alternative designs, especially externally mounted systems, should be considered. We do not think that a collapsible, internally mounted system will be useful. Such systems are prone to leakage, which is very bad for the footing of the horses being transported. They will be very difficult to keep operating, and they will deprive the horses in the trailer of critically needed room.�

At the moment, it appears, there is no practical way to water a trailer load of loose horses during transportation.

The researchers presented their findings to the panel during the meetings. The panel members reached consensus on all of the salient points that appear as part of the regulations. The only major point that produced disagreement involved the banning of double-deck trailers. Ultimately, USDA was asked to assume responsibility for mandating a time frame for the grandfather clause.

As a practical matter, Cordes said, it will take time before the regulations can be implemented, providing they pass basically unchanged through the many agencies that must now review them for a second time. The regulations most importantly require the stamp of approval from the Secretary of Agriculture before they are implemented.

The regulations do not cover all aspects of equine transportation because a regulatory approach of that magnitude basically would be impossible to implement and enforce, Cordes said. �What they do is attempt make certain that the slaughter horse�s last trip is a tolerable one.�

The regulations do not apply to transport of horses from auction to auction, he said, because that is no longer the problem it once was. �The practice today for most slaughter horse buyers is to pick up a few horses at a time and hold them at their home facility until they have enough for a load to send to the slaughter plant. It is when the horses are loaded for that final trip that the regulations come into play.�

USDA statistics indicate that as the horse market has decreased, more care has been taken in the handling of slaughter horses by the buyers. For example, when 348,000 horses were slaughtered in 1989, some 1,300 carcasses were condemned by federal inspectors. In 1998, when about 72,000 horses were slaughtered, the number of carcasses condemned had faded to an �insignificant� number, according to Cordes. The exact number was not available at this writing.

However, Cordes said, abuses involving a minority of shippers still remain and that is the reason for the proposed regulations.

About the Author

Les Sellnow

Les Sellnow is a free-lance writer based near Riverton, Wyo. He specializes in articles on equine research, and operates a ranch where he raises horses and livestock. He has authored several fiction and non-fiction books, including Understanding Equine Lameness and Understanding The Young Horse, published by Eclipse Press and available at www.exclusivelyequine.com or by calling 800/582-5604.

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